Electronically Filed

5/8/2018 12:58 PM
Steven D. Grierson
CLERK OF THE COURT

ANGELA J. LIZADA, ESQ.

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Nevada Bar No. 11637
2 LIZADA LAW FIRM, LTD.
501 S. 7TH St.
3 Las Vegas, NV 89101
Phone: (702) 979-4676
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Fax: (702) 979-4121
5 angela@lizadalaw.com
Attorney for People’s Project, LLC
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DISTRICT COURT
CLARK COUNTY, NEVADA
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9 PEOPLE’S PROJECT LLC, a Nevada Case No.: A-18-774168-C

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Limited Liability Company, Dept. No.:
Department 15
11 Plaintiff,
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v.
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AMY VILELA, an individual, KEENAN
14 KORTH, an individual, DOES I through X,
and ROE CORPORATIONS I through X.
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16 Defendant.

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COMPLAINT
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COMES NOW Plaintiff PEOPLE’S PROJECT, LLC, by and through ANGELA J.
19

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LIZADA, ESQ. of LIZADA LAW FIRM, LTD., and alleges and asserts the following:

21 PARTIES
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1. Plaintiff PEOPLE’S PROJECT, LLC (“PPLLC”) is a Nevada Limited Liability
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Company with its principal place of business in Clark County, Nevada.
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2. Amy Vilela is an individual who is and was a resident of Clark County, Nevada
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at all times relevant hereto.
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3. Keenan Korth is an individual who is and was a resident of Clark County, Nevada
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at all times relevant hereto.
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Case Number: A-18-774168-C

 1 4. The true names and capacities, whether individual, corporate, partnership,
2 associate or otherwise of Defendants DOES I-X and ROE CORPORATIONS I-X are unknown
3 to Plaintiff, who therefore sue said Defendants by such fictitious names. Plaintiff is informed
4 and believes and thereon alleges that each of the Defendants designated herein as DOE and ROE
5 is responsible in some manner for the events and happenings referred to and caused damages
6 proximately to Plaintiff as herein alleged. Plaintiff will ask leave of this Court to amend this
7 Complaint to insert the true names and capacities of DOES I-X and ROE CORPORATIONS I-
8 X when the same have been ascertained, and to join such Defendants in this action.
9 JURISDICTION AND VENUE
10 5. This Court has subject matter jurisdiction pursuant to Article VI of the Nevada
11 Constitution, and personal jurisdiction over Defendant in accordance with NRS 14.065 on the
12 grounds that jurisdiction is not inconsistent with the Nevada Constitution or the United States

13 Constitution.

14 6. Venue is proper in the Eighth Judicial District Court in accordance with NRS

15 13.010 and NRS 13.040.

16 FACTUAL BACKGROUND

17 7. PPLLC is a Nevada limited liability company established in 2017.

18 8. PPLLC had six original managing members when the entity was created: Tisia

19 Stemp, Tom McCullough, Manuel Arizala, Keenan Korth, Sedef Buykataman, and Rose Ann

20 Rabiola Miele.

21 9. The members of PPLLC contributed different sums of money to the creation of

22 the business.

23 10. Keenan Korth (“Mr. Korth”) made no capital contribution to the company.

24 11. Mr. Korth is the only member of PPLLC to receive a draw.

25 12. Mr. Korth, in his capacity as a managing member of PPLLC, entered into a

26 contract (hereinafter referred to as the “Consulting Agreement”) with Amy Vilela (“Mrs.

27 Vilela”).

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 1 13. Under the Consulting Agreement, PPLLC was offering “consulting services in
2 the field of political consulting strategies” explained in further detail under Schedule A attached
3 to the Consulting Agreement.
4 14. PPLLC was to provide part-time consulting services from August 1, 2017 to
5 October 31, 2017.
6 15. PPLLC was to provide full-time consulting services from November 1, 2017 to
7 June 12, 2018.
8 16. Mrs. Vilela agreed to pay $4,000.00 per month plus 6% of the funds raised for
9 the months where PPLLC provided part-time consulting services.
10 17. Mrs. Vilela agreed to pay $8,000.00 per month plus 15% of the funds raised for
11 the months where PPLLC provided part-time consulting services.
12 18. Work began as agreed under the Consulting Agreement in August 2017.

13 19. PPLLC provided food, drink, and lodging for Mrs. Vilela.

14 20. PPLLC provided emotional support and counseling for individual and family

15 discussions.

16 21. PPLLC provided assets for Mrs. Vilela’s grooming, shopping, and dressing.

17 22. PPLLC managed multiple personal issues of Mrs. Vilela’s.

18 23. PPLLC provided free internet service to Mrs. Vilela for five months.

19 24. PPLLC scheduled trips, meetings, events, interviews, phone calls, and Mrs.

20 Vilela’s general calendar for Mrs. Vilela.

21 25. PPLLC provided speechwriting and coaching for Mrs. Vilela.

22 26. PPLLC provided broadcast interview coaching and preparation, provided facility

23 and set design, website, ActBlue, Nationbuilder, and set up bank accounts and post office boxes.

24 27. PPLLC attended political and social organization meetings with Mrs. Vilela and

25 on her behalf.

26 28. PPLLC arranged travel and attendance to the Mobilize 88 conference.

27 29. PPLLC obtained completed endorsement applications and introduce Mrs. Vilela

28 to a campaign manager.

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 1 30. On October 27, 2017, Ms. Vilela paid $2,000.00 on the Consulting Agreement.
2 31. No other payments were made by Ms. Vilela to PPLLC prior to December 2017.
3 32. On December 11, 2017, a meeting was held whereby PPLLC delivered the Notice
4 of Resignation required under the Consulting Agreement.
5 33. The parties met and determined that the total amount due and owing was
6 $22,801.88.
7 34. Mrs. Vilela and Tom McCullough Signed the Termination of Consulting
8 Agreement.
9 35. Under the Termination of Consulting Agreement, Mrs. Vilela agreed to make five
10 payments.
11 36. Mrs. Vilela only made one payment of $3,751.22.
12 37. Mrs. Vilela filed a FEC filing that does not show payments made to PPLLC or

13 the funds owed.

14 38. Upon information and belief, Mr. Korth was personally receiving the funds that

15 were due to PPLLC.

16 39. Mr. Korth has acted against the interests of PPLLC numerous times by competing

17 with the company and making racist and sexist remarks.

18 FIRST CLAIM FOR RELIEF

19 (Breach of Contract)- Amy Vilela

20 40. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

21 27 of the Complaint as though fully set forth herein.

22 41. PPLLC and Mrs. Vilela were parties to a contract.

23 42. PPLLC performed under the agreement until termination of the agreement on

24 December 11, 2017.

25 43. Mrs. Vilela breached the agreement by failing and refusing to make payments

26 under the contract.

27 44. PPLLC sustained damages in the amount of $19,050.66.

28 45. PPLLC was forced to retain counsel to pursue its claims.

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 1 46. PPLLC is entitled to recover its attorneys’ fees and costs under the Consulting
2 Agreement.
3 SECOND CLAIM FOR RELIEF
4 Civil Conspiracy- Amy Vilela and Keenan Korth
5 47. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through
6 46 of the Complaint as though fully set forth herein.
7 48. Defendants, Amy Vilela and Keenan Korth, by acting in concert, intended to
8 accomplish an unlawful objective for the purpose of harming Plaintiff when Defendants
9 breached the contract and Mr. Korth’s fiduciary duty and deprived Plaintiff of the money owed
10 under the Consulting Agreement.
11 49. Plaintiff suffered damages in excess of $15,000.00 as a result of Defendants’ acts.
12 50. Plaintiff was forced to retain counsel to pursue its claims

13 51. Plaintiff is entitled to attorneys’ fees and costs associated with bringing this

14 action.

15 THIRD CLAIM FOR RELIEF

16 Breach of Fiduciary Duty- Keenan Korth

17 52. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

18 51 of the Complaint as though fully set forth herein.

19 53. Mr. Korth as a managing member of PPLLC owed a fiduciary duty to PPLLC.

20 54. Mr. Korth acted breached his duty to PPLLC by interfering in the contractual

21 relationship between PPLLC and Mrs. Vilela and by putting his own financial gains and interests

22 above those of the company.

23 55. Plaintiff sustained damages in excess of $15,000.00 as a proximate cause of Mr.

24 Korth’s breach.

25 56. Plaintiff was forced to retain counsel to pursue this claim, and thus is entitled to

26 attorneys’ fees and costs.

27 57. Plaintiff is entitled to punitive damages as a result of Mr. Korth’s breach of his

28 fiduciary duties.

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 1 FOURTH CLAIM FOR RELIEF
2 Intentional Interference with Contractual Relations- Keenan Korth
3 58. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through
4 57 of the Complaint as though fully set forth herein.
5 59. There was a valid and existing contract between Plaintiff and Mrs. Vilela.
6 60. Mr. Korth knew of the contract.
7 61. Mr. Korth committed intentional acted designed to disrupt Plaintiff’s contract
8 with Mrs. Vilela.
9 62. There was an actual disruption of the contract.
10 63. Plaintiff suffered damages in excess of $15,000.00 as a result.
11 64. Plaintiff was forced to retain counsel to pursue its claim and thus is entitled to
12 recover its attorneys’ fees and costs.

13 FIFTH CLAIM FOR RELIEF

14 Unjust Enrichment- Keenan Korth

15 65. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

16 64 of the Complaint as though fully set forth herein.

17 66. Mr. Korth unjustly retained the moneys owed to Plaintiff under the Consulting

18 Agreement against the fundamental principles of equity and good conscience.

19 67. Mr. Korth unjustly took draws from the company when no other members took

20 draws, and he made no capital contributions to the company.

21 68. Plaintiff is entitled to recover the value of the benefits Mr. Korth received there

22 were rightly Plaintiff’s.

23 69. Plaintiff is entitled to attorneys’ fees and costs for pursuing this matter.

24 SIXTH CLAIM FOR RELIEF

25 Unjust Enrichment- Amy Vilela

26 70. Plaintiff repeats and realleges the allegations contained in Paragraphs 1 through

27 68 of the Complaint as through fully set forth herein.

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 1 71. Plaintiff provide numerous services to Mrs. Vilela which Mrs. Vilela did not
2 compensate Plaintiff for.
3 72. Mrs. Vilela has unjustly retained the money of PPLLC against fundamental
4 principles of equity and good conscience.
5 73. Plaintiff is entitled to damages for the value of the services provided.
6 74. Plaintiff is entitled to recover attorneys’ fees and costs incurred to pursue this
7 action.
8 PRAYER FOR RELIEF
9 WHEREFORE, Plaintiff prays for judgment against Defendants for the following:
10 1. For Amy Vilela to pay Plaintiff in excess of $15,000.00 for breach of contract;
11 2. For Amy Vilela and Keenan Korth to pay Plaintiff in excess of $15,000.00 for civil
12 conspiracy;

13 3. For Keenan Korth to pay Plaintiff in excess of $15,000.00 for breach of fiduciary

14 duties;

15 4. For Keenan Korth to pay Plaintiff in excess of $15,000.00 for intentional interference

16 with a contractual relationship;

17 5. For Keenan Korth to pay Plaintiff in excess of $15,000.00 for unjust enrichment;

18 6. For Amy Vilela to pay Plaintiff in excess of $15,000.00 for unjust enrichment;

19 7. For an award of consequential damages in an amount to be proven at trial;

20 8. For an award of punitive damages against Keenan Korth pursuant to NRS 42.005;

21 9. For all prejudgment and post-judgment interest as provided by law;

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 1 10. For an award of attorneys’ fees and costs incurred in this action; and,
2 11. For any further relief the Court deems just and proper.
3 DATED this 8th day of May, 2015.
4 LIZADA LAW FIRM, LTD.
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ANGELA J. LIZADA, ESQ.
7 Nevada Bar No. 11637
501 S. 7th St.
8 Las Vegas, NV 89101
9 angela@lizadalaw.com

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